https://www.taxtmi.com/caselaws?id=306137 The article notes that bundled technical know-how and advisory services under a consultancy arrangement could not be assigned a nil value merely because the authorities viewed the services as unnecessary or insufficiently beneficial; the transfer pricing adjustment was therefore unsustainable where TNMM could not be displaced without proper basis. It also states that disallowance under section 14A should, in the circumstances discussed, be confined to the amount of exempt dividend income actually earned. Two remaining controversies, concerning depreciation on intangible assets and merger expenses, were treated as requiring fresh factual examination and remand for re-adjudication. en-us Thu, 05 Dec 2019 00:00:00 +0530 Thu, 12 Jan 2023 21:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306137 The article notes that bundled technical know-how and advisory services under a consultancy arrangement could not be assigned a nil value merely because the authorities viewed the services as unnecessary or insufficiently beneficial; the transfer pricing adjustment was therefore unsustainable where TNMM could not be displaced without proper basis. It also states that disallowance under section 14A should, in the circumstances discussed, be confined to the amount of exempt dividend income actually earned. Two remaining controversies, concerning depreciation on intangible assets and merger expenses, were treated as requiring fresh factual examination and remand for re-adjudication. Case-Laws Income Tax Thu, 05 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306137